E.W. Richardson - Page 19

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          body size in its inventory computations subsequent to Richardson            
          I.  In the alternative, respondent determined that Investments              
          made an unauthorized change in method of accounting when it                 
          changed the definition of its inventory units for its new car               
          pool from body size to model line in taxable year 1981.                     
          Petitioner asserts that Investments did not make an unauthorized            
          change in method of accounting in either instance.                          
               Section 446(e) provides that "a taxpayer who changes the               
          method of accounting on the basis of which he regularly computes            
          his income in keeping his books shall, before computing his                 
          taxable income under the new method, secure the consent of the              
          Secretary."11  The Internal Revenue Code does not define the                
          phrase “change in method of accounting”.  However, the                      
          regulations under section 446(e) provide that a “change in the              
          method of accounting includes a change in the overall plan of               
          accounting for gross income or deductions or a change in the                
          treatment of any material item used in such overall plan.”  Sec.            
          1.446-1(e)(2)(ii)(a), Income Tax Regs.  Furthermore, with respect           
          to inventories, the regulations provide:                                    
               A change in an overall plan or system of identifying or                
               valuing items in inventory is a change in method of                    
               accounting.  Also a change in the treatment of any material            
               item used in the overall plan for identifying or valuing               
               items in inventory is a change in method of accounting.                
               [Sec. 1.446-1(e)(2)(ii)(c), Income Tax Regs.]                          



          11   Consent is requested by filing an application on Form 3115.            
          Sec. 1.446-1(e)(3)(i), Income Tax Regs.                                     



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